Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)
Sections 5.3 and 5.4: Monitoring ICT use at and outside the workplace – Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)

Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249) 5.4.3: 5.4.3 Mobile device management: DPIA first, a specified purpose, tracking held back until a device is lost

A DPIA should precede any new mobile device management technology, and even where it is necessary the processing must still meet proportionality and subsidiarity. Location data must serve a specified purpose and must not become part of ongoing employee monitoring; tracking should be mitigated, for instance by registering location without showing it to the employer unless the device is reported lost or stolen. Employees whose devices are enrolled must be fully informed of the tracking and its consequences.

Maintained by Gerard Blokdyk

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Other controls in Sections 5.3 and 5.4: Monitoring ICT use at and outside the workplace – Article 29 Working Party Opinion 2/2017 on Data Processing at Work (WP249)

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